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The MSDS (International Format): A Brief Summary Of Canadian Requirements


Although the term "material safety data sheet (MSDS)" is used internationally, different jurisdictions have different content requirements. For example, an MSDS prepared in accordance with the United States OSHA Hazard Communication Standard (HCS), does not necessarily comply with regulatory requirements in other jurisdictions.

An internationally-harmonized 16-heading MSDS format has been developed. This "international format" has been adopted by the European Union (EU), the International Standards Organization (ISO) and the International Labour Organization (ILO) and is documented in ANSI (American National Standards Institute) Standard Z400.1-1993. Use of this format meets U.S. OSHA requirements (as long as all required information is included). In Canada, regulatory authorities have agreed to allow the use of the 16-heading format, provided that all of the MSDS information required under the Controlled Products Regulations is included and that a statement on the MSDS indicates that (1) the product was classified in accordance with the hazard criteria of the Canadian Controlled Products Regulations and (2) the MSDS contains all the information required by those regulations.

Preface

Although every effort is made to ensure accuracy and completeness of the information, it is understood that CCOHS makes no warranty as to the accuracy or completeness of such information and assumes no liability for any damages or loss suffered as a result of any inaccuracy or incompleteness therein.

Publications Number P96-9E
DSS Catalogue Number CC273-2\96-9E
ISBN Number 0-660-16705-0

Yvonne Pietersma
Robert Whiting

Published: 1996

CCOHS
250 Main Street East
Hamilton, Ontario
L8N 1H6
905-572-2981
905-572-2206 (Fax )

Introduction

Although the term "material safety data sheet (MSDS)" is used internationally, different jurisdictions have different content requirements. For example, an MSDS prepared in accordance with the United States OSHA Hazard Communication Standard (HCS), does not necessarily comply with regulatory requirements in other jurisdictions.

An internationally-harmonized 16-heading MSDS format has been developed. This "international format" has been adopted by the European Union (EU), the International Standards Organization (ISO) and the International Labour Organization (ILO) and is documented in ANSI (American National Standards Institute) Standard Z400.1-1993. Use of this format meets U.S. OSHA requirements (as long as all required information is included). In Canada, regulatory authorities have agreed to allow the use of the 16-heading format, provided that all of the MSDS information required under the Controlled Products Regulations is included and that a statement on the MSDS indicates that (1) the product was classified in accordance with the hazard criteria of the Canadian Controlled Products Regulations and (2) the MSDS contains all the information required by those regulations.

The acceptance of the international MSDS format by regulatory bodies makes it possible to incorporate the information requirements of multiple jurisdictions on one data sheet, thus simplifying the requirements for companies who sell products internationally. Caution must be exercised, however, since different jurisdictions may use slightly different definitions or criteria for flammability, toxicity, and so on. In these cases, the international MSDS must make it clear which jurisdictions' definitions have been used in preparing the information. Guidance concerning Canadian and U.S. definitions is provided in the CCOHS publication "The Material Safety Data Sheet - An Explanation of Common Terms". The applicable regulations should also be consulted.

Content requirements for Canadian MSDSs under WHMIS (the Workplace Hazardous Materials Information System) are set out in the federal Controlled Products Regulations. Schedule 1, Column III of these regulations lists 53 subheadings (information items) for material safety data sheets. Three of these are mandatory and must be disclosed in all cases: (1) the ingredients of the product, (2) the party responsible for preparing the MSDS (name and phone number) and (3) the date the sheet was prepared. All other information items must be included IF AVAILABLE AND APPLICABLE. There is no requirement for a supplier to conduct toxicological testing before classifying the material and publishing an MSDS. However, it is expected that suppliers will conduct tests for flammability, vapour pressure for compressed gases and corrosivity to metals, if data are not available.

It is generally recommended that each subheading should be shown on the MSDS and "not applicable" and "not available" should be used as appropriate. It should be noted that, to prevent confusion, the abbreviation "n.a." should not be used for "not available" as some readers may interpret it to mean "not applicable.

A good quality material safety data sheet will use commonly understood language and will minimize the use of technical jargon and unexplained abbreviations.

This document is designed for technical users or writers of international format MSDSs who want to understand Canadian requirements. All of the subheadings (information items) required under the controlled products regulations are listed below. They have been numbered and arranged under the 16 headings of the international format MSDS. Mandatory subheadings are marked with an asterisk. It should be noted that alternative arrangements of the subheadings are certainly possible and would be acceptable under Canadian WHMIS.

Writers of international-format MSDSs for Canadian workplaces should consult the following documents:

(1) ANSI standard Z400.1-1993 "Standard for Hazardous Industrial Chemicals - Material Safety Data Sheets - Preparation";
(2) WHMIS Core Manual published by the Worker's Compensation Board of British Columbia;
(3) WHMIS Information Bulletins published by the Health Protection Branch of Health Canada; and
(4) the federal Controlled Products Regulations. Full references are listed at the end of this document.

1. Chemical Product And Company Identification

(1) Product identifier
The product identifier on the MSDS must exactly match the product identifier on the WHMIS label for the product.

(2) Manufacturer's name, street address, city, province, postal code and emergency telephone number

(3) Supplier identifier, street address, city, province, postal code and emergency telephone number

(4) Product use
Information on the anticipated uses of the product can be valuable to the end-user because it indicates whether the way the product is used in his/her workplace is typical. This may be helpful, since some of the MSDS information may be relevant to specific usage situations only. If a mode of usage is uncommon, it may be necessary to request more health and safety information from the supplier/manufacturer.

*(5) Name and phone number of the group, department, or party responsible for the preparation of the MSDS

*(6) Date of preparation of the MSDS
The Controlled Products Regulations require that the MSDS be revised whenever any significant new information becomes available. In addition, the MSDS information must be routinely reviewed (and revised if necessary) at least every 3 years. The date must be changed whenever this is done.

2. Composition/Information on Ingredients

*(1) Ingredients/Components
Section 13(a) of the Hazardous Products Act requires chemical ingredients to be specifically listed if:

(i) they are controlled products and are present at 1.0% or more (or 0.1% or more for teratogens, embryotoxins, carcinogens, reproductive toxins, respiratory tract sensitizers and mutagens).

(ii) they are on the WHMIS Ingredient Disclosure List, and are present at a concentration that is greater than or equal to the concentration specified on the list,

(iii) the supplier has reasonable grounds to believe that they may be harmful to any person,

OR

(iv) they have unknown toxicological properties

For each ingredient, the concentration expressed as percent weight/weight, percent volume/volume or percent weight/volume must be indicated. If the ingredient is not always present in the same concentration, concentration ranges can be used (acceptable ranges are specified in the Controlled Products Regulations).

(2) CAS Registry Number (for each ingredient)

(3) LD50 (species and route) for each ingredient.

If there are LD50 data for the PRODUCT (mixture), they must be disclosed instead of the data for ingredients and would likely be placed in Section 11, Toxicological Information.

(4) LC50 (species and route) for each ingredient.

If there are data for the PRODUCT (mixture), they must be disclosed instead of the data for ingredients and would likely be placed in Section 11, Toxicological Information.

(5) Exposure limits for ingredients

Exposure limits for the PRODUCT (mixture) must also be included on the MSDS, if they are available. These would normally be included in section 8, Exposure Controls, Personal Protection. The MSDS should indicate whether the exposure limit has been published by the ACGIH or AIHA, whether it is a regulatory limit or if it has been recommended by the manufacturer/supplier.

Confidential Business Information (Trade Secrets):

Where a claim for exemption to disclose an ingredient has been filed under the Canadian Hazardous Materials Information Review Act, the generic chemical identity of the ingredient must be disclosed on the MSDS along with the date the claim was filed and the registration number assigned by the Hazardous Materials Information Review Commission.

3. Hazards Identification

3.1 Emergency overview

This section is intended as a quick reference for emergency responders. There are no specific Canadian WHMIS requirements for this subsection.

3.2 Potential health effects

(1) Route of entry (including skin contact, skin absorption, eye contact, inhalation and ingestion)

(2) Effects of acute exposure

(3) Effects of chronic exposure

The intent of this section is to include any health effects which are judged to be relevant to HUMANS, taking into account all reasonably anticipated uses of the material or accidental exposure situations.

4. First Aid Measures

(1) Specific first aid measures

Each route of exposure should be addressed. It is advisable to separate actions to be taken in the workplace from medical treatment information aimed at health care professionals.

5. Fire Fighting Measures

(1) Conditions of flammability

(2) Means of extinction

(3) Flash point and method of determination

Closed cup flash points are generally preferred over open cup flash points.

(4) Upper flammable limit

(5) Lower flammable limit

(6) Auto-ignition temperature

(7) Hazardous combustion products

It is helpful to differentiate between combustion products (from burning), thermal decomposition products (from heating with no flames) and decomposition products resulting from normal environmental conditions (air, water and light exposure), which would appear in section 10.

(8) Explosion data - sensitivity to mechanical impact

(9) Explosion data - sensitivity to static discharge

6. Accidental Release Measures

(1)Procedures to be followed in case of a leak or spill

7. Handling And Storage

(1) Handling procedures and equipment

(2) Storage requirements

8. Exposure Controls/Personal Protection

(1) Specific engineering controls to be used

(2) Personal protective equipment to be used

The material safety data sheet should differentiate between more hazardous and less hazardous materials and should not provide "worst case" recommendations only.

9. Physical And Chemical Properties

(1) Physical state (i.e. gas, liquid or solid)

(2) Odour and appearance

(3) Odour threshold (detection thresholds and identification thresholds)

It is helpful to indicate how adequate the warning properties are for the material, considering both irritation and odour, if this information is known.

(4) Specific gravity

(5) Vapour pressure

(6) Vapour density

(7) Evaporation rate (compared to a reference solvent, typically diethyl ether or n-butyl acetate)

(8) Boiling point

(9) Freezing point/melting point

(10) pH

(11) Coefficient of water/oil distribution

10. Stability And Reactivity

(1) Conditions under which the product is chemically unstable

(2) Name of any substance or class of substance with which the product is incompatible

(3) Conditions of reactivity

It is useful to include the products of reaction and the possible outcomes of the reaction.

(4) Hazardous decomposition products

It is advisable to list products of decomposition from reasonably anticipated conditions of use, for example, exposure to air, light or water.

11. Toxicological Information

(1) Irritancy The degree of irritation should be noted, as well as whether the information relates to irritation of the eyes, mucous membranes or skin. The basis for the information (for example, a Draize test) should be included. Substances causing irritation after short-term exposures should be distinguished from those that cause effects only after repeated or prolonged contact.

(2) Sensitization

Both respiratory sensitizers and skin sensitizers should identified. If an ingredient has the potential to cause sensitization at low airborne concentrations or to cause severe allergic reactions, this should be highlighted.

(3) Carcinogenicity

If the product contains a recognized or possible carcinogen, it is advisable to indicate the type of carcinogen (known, suspected, probable, or possible) and which organization(s) have recognized the substance as a carcinogen.

(4) Reproductive toxicity

(5) Teratogenicity

Since many chemicals can cause reproductive and teratogenic effects at sufficiently high doses in experimental animals, it is important to focus on any effects that were found at low doses or in the absence of maternal toxicity.

(6) Mutagenicity

(7) Name of toxicologically synergistic products

Additional sections under the headings, "Effects of Acute Exposure" and "Effects of Chronic Exposure" would be useful as well, so that the corresponding animal toxicity data can be included.

If any of this toxicological information is judged to be also applicable to human occupational or emergency exposures, it should be included in Section 3, Hazards Identification, as well.

12. Ecological Information

WHMIS does not require any specific information items in this section. Normally, information on toxicity to fish, plants, birds and microorganisms, persistence in the environment, bioaccumulation and soil mobility would be included.

13. Disposal Considerations

(1) Waste disposal

Reference should be made to federal and provincial regulations which may apply, such as the Canadian Environmental Protection Act. It is advisable to include a reminder that local regulations should be consulted as well.

14. Transport Information

(1) PIN number (product identification number as defined in the Canadian Transportation of Dangerous Goods (TDG) act and regulations).

The TDG PIN number is a four digit number preceded by the prefix UN or NA.

(2) Special shipping information

The TDG classification and label information and any other information relevant to the safe transport of the material (for example, sensitivity to mechanical shock or high temperatures) should be indicated.

15. Regulatory Information

Material safety data sheets written for Canada should include a statement such as "This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations and the MSDS contains all of the information required by those regulations."

It is advisable to include the WHMIS classification here as well.

16. Other Information

There are no other information items specifically required under WHMIS. This section of the MSDS can be used to provide label information, NFPA (U.S. National Fire Protection Association) hazard ratings, name and phone number of person to contact for more information, a legal disclaimer, revision indicators (dates and sections revised), or any other information that may be important.

Useful Sources Of Additional Information

ANSI standard Z400.1-1993. Material Safety Data Sheets - Preparation. American National Standards Institute, 1993.

Controlled Products Regulations. (SOR 88-66 as emended by SOR 88-555 and SOR 89-150). Canada Gazette Part II, Vol 122, No. 2. 20/1/88.

WHMIS Core Manual. Worker's Compensation Board of British Columbia, January, 1991.

WHMIS Information Bulletins. Available from Health Canada, Health Protection Branch.



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